playday not payday:

1The Good Childhood Report 2014

Introduction

Playday not payday: Protecting children from irresponsible payday loan advertising

3

IntroductionIn the past few years, there has been widespread concern about the frequency with which families are turning to the use of payday loans in order to make ends meet. Our recent ‘Debt Trap’ report that we published with Stepchange Debt Charity found that a third of families with children have borrowed

money to pay for essentials for their children in the last year.

Too often, the impact problem debt has on children is overlooked. The Debt Trap1 found that the existence of problem debt was associated with arguments in the family, stress in the home, bullying at school, and parents cutting back on essential items like food, clothing and heating.

1 http://www.childrenssociety.org.uk/sites/default/files/debt_trap_report_may_2014.pdf2 http://stakeholders.ofcom.org.uk/binaries/research/tv-research/Trends-advertising-activity.pdf 3 http://www.childrenssociety.org.uk/sites/default/files/debt_trap_report_may_2014.pdf4 http://media.ofcom.org.uk/news/2013/Ofcom-research-payday-loan-TV-adverts/

Key findings

Around three quarters ( 74%) of parents of children aged 18 or under think payday loan advertisements should be banned from television and radio before the watershed.

Just over 6 in 10 of the parents surveyed (61%) believe that seeing payday loan advertisements make children believe these are a normal way to manage money.

A third of children aged 13–17 (34%) say they think payday loan advertisements are fun, tempting or exciting. Of this group, a quarter say they would consider using payday loans when they are adults.

Almost three quarters (72%) of children aged 13–17 say they have seen at least one payday loan advertisement in the last week and over two thirds (68%) say they had seen at least one on television.

Over half (55%) of children aged 13–17 were able to recognise the names of at least three payday lenders. Only 7% recognised none.

More than 4 in 10 of the parents surveyed (42%) who have taken out a payday loan in the past are contacted by payday loan companies more than once a day.

At the same time, the number of payday loan adverts being seen by children aged 4–15 increased from three million in 2008 to 596 million in 2012 – an increase of almost 200 times more adverts being shown.2 Our research found that the majority of children aged 10–17 said they saw advertising for payday loans ‘often’ or ‘all the time’.3

Our new report reveals that nearly three quarters of the children aged 13–17 we surveyed online had seen or heard at least one payday loan advert in the last seven days – with just over two thirds having seen a payday loan advert just on television alone during the last week. Ofcom research found that in 2012, 80% of all payday loans advertisements on TV were broadcast pre-watershed.

4 The Debt Trap: Payday loan advertising and children

There is general acceptance of the principle of advertising restrictions on certain items viewed as harmful or inappropriate for children in a number in areas such as junk food,5 gambling6 and alcohol.7 There is also significant appetite from parents, politicians and many campaign groups to place payday loans in the same category. For example, our online research found that nearly three quarters of parents would like to see a ban on payday loan advertising before the watershed.

We know from our research that payday lenders are the most likely to treat vulnerable parents negatively with up to 42% of parents who had struggled with bills or credit commitments saying that they were treated ‘badly’ or ‘very badly’.8 So there is an argument that the potential harm in the misuse of payday loans – much like alcohol and gambling – could be seen as reason to limit the use of their advertising to children.

The practices of payday lenders including advertising tactics have come under much scrutiny both in the press and in parliament. These have led to much wider criticism of the work of payday lenders. For example, in December 2013, the Business, Innovation and Skills Committee reviewed the rules and regulations on payday lenders, resulting in a number of changes to the regulations9 and a review of practice by the Broadcast Committee of Advertising Practice.10

However, as yet there has been no action on advertising regulation – and payday loans remain immune from scheduling restrictions. While all adverts are subject to broad content guidelines, this overlooks concerns about the broader prevalence of payday lending advertisements, the long term effects on financial education and the specific use of advertising practices that indirectly target children.

Our research makes clear that the potential harm of the misuse of payday loans – much like alcohol and gambling – is justification to limit the use of their advertising to reduce the amount seen by children. Payday loan advertisements have two main effects: the direct impact of ‘pester power’ on parents and families to take out short term, high cost credit; and a long term normalisation among young people of payday loans as an appropriate way to manage day-to-day expenses.

There is an urgent need for further action by government, regulators and local authorities to do more to ensure that children are learning about consumer credit and good financial practices through schools and not through misleading and enticing adverts.

5 http://www.sustainweb.org/childrensfoodcampaign/junk_food_marketing/#3 6 http://www.publications.parliament.uk/pa/ld201314/ldhansrd/text/140304-0002.htm#14030473000570 7 http://www.alcoholconcern.org.uk/publications/policy-reports/stick-to-the-facts 8 http://www.childrenssociety.org.uk/sites/default/files/debt_trap_report_may_2014.pdf 9 http://www.publications.parliament.uk/pa/cm201314/cmselect/cmbis/789/789.pdf 10 http://www.cap.org.uk/News-reports/Media-Centre/2014/BCAP-Payday-Loans-Review.aspx#.VBABanI73pU

Methodology

All figures, unless otherwise stated, are from surveys of parents of children aged 18 or under, and of children aged 13–17, from YouGov Plc.

Parents of children aged 18 or under: Sample size was 1065 adults. Fieldwork was undertaken between 3–5 September 2014. The figures have been weighted and are representative of GB parents of children aged 18 or under.

Children aged 13–17: Sample size was 680. Fieldwork was undertaken between 29 August–3 September 2014. The figures have been weighted and are representative of GB children aged 13–17. Both surveys were carried out online.

5The Debt Trap: Payday loan advertising and children

Recommendations

Local authorities Prevent payday loan

companies from advertising on or within council property. Reducing the number of payday loan adverts in the area will reduce the number of residents taking out payday loans and therefore falling into problem debt.

Block payday loan company websites on local authority public computers and internet and redirect to credit unions. More focus should be put on providing residents with access to affordable credit such as credit unions.

Recommendations

Regulators Revise the Broadcasting

Committee of Advertising Practice codes to define any reference to children as under-18. This will make the codes more consistent and therefore easier for the public to understand and regulators to enforce.

Close the gap in the law that allows consumer credit providers to contact people using unsolicited marketing calls. This will prevent families from being relentlessly targeted at home and work by payday lenders.

Recommendations

Government Ban payday loan

advertisements from being broadcast pre-watershed on both television and radio. This will significantly reduce the inappropriate exposure of misleading payday loan adverts to children.

Ban payday loan advertisements from being shown around programmes likely to appeal to children. This will make sure the safeguards extend to all children’s broadcasting.

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The situation can be exacerbated by loan companies persistently using misleading adverts that aim to minimise the impact and seriousness of taking out a payday loan. For example, one payday lender had a television advert banned for ‘implying a representative APR was irrelevant to a short-term loan’.12

Another payday loan company recently agreed to change their advertising campaigns to remove the use of puppets as they did not want to be associated with anything which ‘inadvertently attracts children’.13 This is just one of many examples of loan companies using animated characters or catchy songs. Research by MoneySavingExpert.com found that one in three people with children under-10 had heard their kids repeat payday loan slogans.14

The subconscious appeal to children and young people through these methods is well researched and in relation to alcoholic drinks, has led to explicit guidance to prevent adverts inadvertently targeting young audiences. This includes a ban on: personalities with

Too often families are driven to use high cost short term credit because they see no other alternative. Our recent research with Stepchange Debt Charity found that a

third of families had borrowed money in order to pay for essentials.11

What’s the problem?

11 http://www.childrenssociety.org.uk/sites/default/files/debt_trap_report_may_2014.pdf12 http://www.asa.org.uk/Rulings/Adjudications/2014/4/WDFC-UK-Ltd/SHP_ADJ_246696.aspx#.VAcqpXI73pU 13 http://www.bbc.co.uk/news/business-28294258 14 http://www.moneysavingexpert.com/news/loans/2013/11/payday-loan-ads-should-be-banned-from-kids-tv-moneysavingexpert-com-says15 http://www.cap.org.uk/CAP-and-BCAP-Consultations/Closed-consultations/~/media/Files/CAP/Consultations/BCAP_considerations_to_responses.ashx 16 http://stakeholders.ofcom.org.uk/binaries/research/tv-research/Trends-advertising-activity.pdf17 http://www.which.co.uk/news/2013/01/payday-loans-advertising-on-childrens-tv-309136

specifically aimed at children17 we found that over half (55%) of children aged 13–17 know three or more of the top payday loan companies. This suggests that, even as the nature and location of shows being watched by children change, the effect is still the same.

Our research found that nearly three quarters of children aged 13–17 had seen or heard at least one payday loan advert in the last seven days.

a strong youth appeal; themes and language associated with young people; teenage fashion, clothing and music; cartoons, rhymes, animation, puppets and animals ‘likely to inspire strong affection in the young’.15

There is evidence that children are seeing more payday loan adverts than ever before.16 Although a recent review indicated that payday lenders are reducing the amount spent on television adverts

Figure 1: Percentage of 13–17 year olds who said they had seen or heard a payday loan advert in the last seven days by media

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Source: 2014 YouGov survey, ages 13-17, n=680


34%of parents believe payday loan adverts deliberately target children

27%think payday lenders pressure children to pester their parents to borrow money

Pester powerFar from being an inevitable knock-on effect of successful marketing to adults, there is evidence to suggest that children exposed to particularly suggestive payday loan adverts are then asking and pressuring their parents to take out a loan to pay for things which they have not been allowed.

We found that more than a third of parents (34%) believe payday lenders’ adverts deliberately target children. And more than one quarter (27%) think the companies put pressure on children to pester their parents to borrow money. Research by MoneySavingExpert.com found that 14% of parents said that, when they have refused to buy something for their child under 10 they have been nagged to take out a payday loan to pay for it.18

Our polling found that children were significantly more likely to suggest to their parents that they take out a payday loan, if parents had taken out a payday loan in the past.

Figure 2: Proportion of parents reporting that their children have suggested they take out a payday loan

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30%

Have used a payday loanHave never used a payday loan

3%

27%

18 http://www.moneysavingexpert.com/news/loans/2013/11/payday-loan-ads-should-be-banned-from-kids-tv-moneysavingexpert-com-says

Source: 2014 YouGov survey, n=1127


Children’s development and long term attitudesThe inconsistencies between different codes and guidelines in advertising across different media and aimed at different ages are widely recognised. However, where there is evidence of a negative impact on children, regulation is enforced. For example, advertising alcoholic beverages is heavily regulated. Reasons cited for this include preventing the normalisation and abuse of alcohol. Similar logic should be applied to the advertising of payday loans. Martin Lewis, founder of MoneySavingExpert.com recently said:

‘This vicious circle means we now see [payday] loans normalised. That’s why we need legislation or regulation to disrupt this market.

‘The payday loan industry insists it is not targeting children, but our research shows that kids are being dazzled by catchy tunes and cute puppets’19

Our research found evidence to support this and showed that one in three (34%) children aged 13–17 described payday loan advertisements as ‘fun’, ‘tempting’

19 http://www.moneysavingexpert.com/news/loans/2013/11/payday-loan-ads-should-be-banned-from-kids-tv-moneysavingexpert-com-says 20 Analysis conducted by The Children’s Society based on YouGov figures21 The sample size of parents aged 18-24 in the survey is small (base = 28). However, the findings showed a statistically significant difference in payday loan use

by age group (p=0.000)

Figure 3: Children aged 13–17 seeing payday loan adverts as fun, tempting or exciting and their attitudes to payday loans

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Teenagers seeing payday loan ads as fun, tempting or exciting

Teenagers not seeing payday loan ads as fun, tempting or exciting

I would consider using payday loans to pay for

day-to-day things I need (e.g. grocery shopping, bills etc.)

I would consider using payday loans BUT only

for emergencies

I would never use payday loans

1% 2%

13%

24%

74%

87%

or ‘exciting’.20 These children were considerably more likely to say they would consider using payday loans with more than a quarter of this group saying they would consider using them.

In our survey, 61% of parents with children aged 18 or under said they believe that seeing these adverts make children believe payday loans are an everyday way of managing money (see Figure 4).

Perhaps as a result of having grown up in an environment in which the use of payday loans is

increasingly normalised, young parents are particularly likely to use payday loans. We found that 39% of parents aged 18–24 in our poll21 have used payday loans, compared to just 18% of 25–34 year olds, and 8% of 35–44 year old parents (see Figure 5).

In April of this year, the Financial Conduct Authority (FCA) took over the role of regulating payday lenders. Recent research by the FCA found that 20% of consumer credit advertisements are misleading customers. The FCA also found that a payday lender was targeting

Source: 2014 YouGov survey, ages 13-17, n=680


young audiences by ‘distributing branded colouring-in sheets with their pamphlets for high-cost, short-term loans’.23

It is alarming that payday lenders are creating specific items for children to use when they are unable to take out a payday loan. We are concerned this is contributing to the normalisation of payday loans as an acceptable form of managing day-to-day finances rather than a form of credit to be used appropriately and sparingly. Tighter regulation around offline advertising products aimed at children is needed.

Restrictions on advertising payday loans would have widespread support from parents. Three quarters of parents said that they would be in favour of a ban on payday loan advertising before 9pm, with half of parents strongly agreeing with this proposition.

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Don't know

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Tend toagree

Stronglyagree

24%

36%

20%

8%

3%

9%

Figure 4: Parents’ responses ‘Seeing payday loan adverts make children believe these loans are an everyday way of managing money’

Figure 5: Proportion of parents who have taken out a payday loan by age of parent22

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55+45–5435–4425–3418–24

39%

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1%

22 ibid23 http://www.fca.org.uk/news/consumer-credit-firms-must-raise-advertising-standards

RecommendationTo reduce children pestering their parents and to minimise long term impact of the normalisation of payday loans, adverts for payday loans should be prevented from being shown before the watershed at 9pm.

RecommendationFurther restrictions should be put in place to prevent payday loan adverts from being shown during programmes targeted at children including children’s television.




24 http://www.plymouth.gov.uk/homepage/councilanddemocracy/aboutus/cooperativestory/coopenterprise.htm 25 http://moderngov.towerhamlets.gov.uk/documents/s51313/Report%20Motions%20Council%2027.11.13.pdf 26 http://www.localgov.co.uk/Councils-mull-payday-lenders-billboard-ban/28573 27 http://www.bbc.co.uk/news/uk-england-tyne-23603880 28 http://www.brent.gov.uk/council-news/press-releases/pr5640/ 29 http://www.cap.org.uk/Advertising-Codes/Broadcast-HTML.aspx

47%

26%

15%

4% 3% 4%

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Figure 6: Proportion of parents who would like to see a ban on payday loan advertising before the watershed

Other restricted productsAlcohol, gambling, junk food and sexual imagery all have their television and radio broadcast advertising regulated to protect children from inappropriate viewing under the Broadcasting Committee of Advertising Practice.29 Lessons can be learned from the regulation of these adverts and how they can be applied to payday loan adverts to protect children. Further detail is provided in Appendix 1.

RecommendationLocal authorities should block payday loan company websites on local authority public computers and internet and redirect users to credit unions. This would put more focus on providing residents with access to affordable credit such as credit unions.

RecommendationSimilarly to restrictions for alcohol, payday loan advertisements should be prevented from being shown in or around television and radio programmes that are deemed to be aimed at or of particular interest to children under-18.

The role of local authorities Recently there have been a number of actions from local authorities to try and reduce the exposure of payday loan adverts in their constituencies. In 2013, Plymouth City Council were the first to take action by banning payday loan advertisements on council-owned bus stops and billboards.24 Tower Hamlets have since followed suit25 with several others also considering a ban.26 This will also allow more low-cost advertising space for local businesses and organisations.

Newcastle City Council,27 and Brent Council28 have restricted access

to payday lender websites from council computers. Brent Council have used this to redirect people to local providers of affordable credit such as credit unions to try and reduce the number of people getting into problem debt.

RecommendationLocal authorities should consider their role in reducing the presence of payday loan advertisements in their area – specifically in relation to places where children are likely to see them, for example near schools and playgrounds.



RecommendationClosing the gap in the regulation to prevent payday loan companies from making unsolicited marketing calls would be an important step towards protecting vulnerable families.

TelemarketingA recent briefing by Stepchange Debt Charity highlighted a gap in the regulatory rules that allows payday lenders to contact people using unsolicited marketing calls offering them a payday loan.30 Under current regulations, mortgage providers and other types of lenders are prevented from using these calls but this method of sales is permitted for high-cost credit.

Around 1 in 10 parents say that they are contacted by payday loan companies more than once per day. This was a particular problem for those who had taken out a payday loan in the past – more than 4 in 10 parents who had taken out a payday loan were contacted more than once per day.

Stepchange research also found that 15% of their clients who were offered a loan took out high cost credit as a result of unsolicited calls. Those who said they were receiving these types of calls were receiving an average of 10 calls per day.31

30 Also known as ‘unsolicited real-time promotion’ http://www.stepchange.org/Portals/0/documents/media/reports/StepChange_Debt_Charity_briefing_on_unsolicted_marketing_of_payday_loans.pdf

31 http://www.stepchange.org/Portals/0/documents/media/reports/StepChange_Debt_Charity_briefing_on_unsolicted_marketing_of_payday_loans.pdf 32 Analysis conducted by The Children’s Society on the basis of YouGov figures

Figure 7: Parents contacted by payday loan companies more than once per day32

0%

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20%

25%

30%

35%

40%

45%

TotalHave used a payday loan

Have never used a payday loan

7%

42%

11%

People often find themselves on these databases because they have either taken out or considered taking out a loan previously. We are also concerned about the effect this targeting of often very vulnerable families will have on the mental health of both the parents and the children living in the family.



The current law

Advertising and childrenJuly this year marked the 50th anniversary of the watershed being made into law by parliament and described by Ofcom as a ‘vital tool in protecting young viewers’.33 However, the watershed is just one of many rules and regulations aimed at reducing the inappropriate viewing and listening of shows and advertisements by children. Technological advances have made it important to also consider additional approaches to protect younger consumers.

For example, the Broadcasting Committee of Advertising Practice (BCAP) – which prescribes the rules for advertising on television and radio that are enforced by the Advertising Standards Authority – says that ‘children must be protected from advertisements that could cause physical, mental or moral harm.’34 Furthermore, the first standards objective of Ofcom, laid out in the Communications Act 2003, is ‘that persons under the age of eighteen are protected’.35

There is a broad commitment to ensure that communications and advertising protect children. However, we are concerned that the legislation is inconsistent leading to confusion – for example BCAP defines a child as someone under-16 whereas the Ofcom standards code refers to under-18s. Also, some parts of the BCAP, such as the alcohol sections, refer to under-18s. So even within specific codes there is a lack of clarity and consistency.

Role of the regulatorsAs of April this year, the Financial Conduct Authority took over responsibility for the regulation of organisations providing consumer credit – including payday lenders. This involves setting the rules which lenders have to follow and intervening where firms are failing to meet them.36

On advertising by payday lenders, the Advertising Standards Authority (ASA) have responsibility for investigating adverts that have been reported to them as ‘irresponsible’ or ‘misleading’. Adverts that are considered irresponsible includes adverts aimed at under-18s and vulnerable people.

In recent months, the ASA have taken steps to ban some adverts that break the rules.37 However, with the FCA reporting 20% of adverts having broken advertising rules38 there is a continued risk of poor advertising practice.

RecommendationRegulations and codes could be more aptly followed by companies if there was more consistency around what age qualifies as a child. Given the increasing move towards more responsibilities for children up to the age of 18 – such as having to stay in school or training until 18, it would seem appropriate to match this and make the age at which someone is considered a child as under-18.

33 http://media.ofcom.org.uk/news/2014/50-years-watershed34 http://www.cap.org.uk/Advertising-Codes/~/media/Files/CAP/Codes%20BCAP%20pdf/BCAP%20Codes%2017_6_2014.ashx 35 http://www.legislation.gov.uk/ukpga/2003/21/contents 36 http://www.fca.org.uk/consumers/financial-services-products/loans-and-credit 37 http://www.citizensadvice.org.uk/index/pressoffice/press_index/press_20140730.htm 38 http://www.fca.org.uk/news/consumer-credit-firms-must-raise-advertising-standards

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Children should be learning about debt and money from their school and family – not from irresponsible payday loan advertising.

39 Analysis conducted by The Children’s Society on the basis of figures from YouGov. The sample size for parents aged 18-24 is small (base = 28). However, the difference by age group is statistically significant.

Payday loan advertisements have two main effects:

The direct impact of ‘pester power’ on parents and families to take out loans

The long term normalisation among young people of high cost, short term credit as an appropriate way to deal with everyday expenses.

Conclusion

Recommendations

Ban payday loan advertisements from being shown pre-watershed on both television and radio.

Ban payday loan advertisements from being shown around programmes likely to appeal to children.

Revise the Broadcasting Committee of Advertising Practice codes to define any reference to children as under-18.

Close the gap in the law that allows consumer credit providers to contact people using unsolicited marketing calls.

Prevent payday loan companies from advertising on or within council property.

Block payday loan company websites on local authority public computers and internet and redirect to credit unions.

We have already begun to see the effect of this with 30% of 18–24 year old parents describing payday loans as an acceptable way of to manage day-to-day expenses – significantly more than older parents.39 Payday loan advertising is also putting even more pressure on families struggling to make ends meet.

Urgent action needs to be taken by national government, local government and regulators to contain the impact payday loan advertisements have and further protect children from being inappropriately targeted.

14

Children’s television scheduling rules Age at which rules apply

The Broadcasting Committee of Advertising Practice codes create a number of rules regarding the placement of advertisements around children’s television. The codes on scheduling state:

Under-18s32.2 These may not be advertised in or adjacent to programmes commissioned for,

principally directed at or likely to appeal particularly to audiences below the age of 18:

32.2.1 alcoholic drinks containing 1.2% alcohol or more by volume (see rule 32.4.7) 32.2.2 gambling except lotteries, football pools, equal-chance gaming (under a prize

gaming permit or at a licensed family entertainment centre), prize gaming (at a non-licensed family entertainment centre or at a travelling fair) or Category D gaming machines (see rule 32.4)

Under-16s32.3 Relevant timing restrictions must be applied to advertisements that, through

their content, might harm or distress children of particular ages or that are otherwise unsuitable for them.

32.4 These products may not be advertised in or adjacent to programmes commissioned for, principally directed at or likely to appeal particularly to persons below the age of 16:

32.4.1 lotteries32.4.7 drinks containing less than 1.2% alcohol by volume when presented as low-

alcohol or no-alcohol versions of an alcoholic drink32.5.1 food or drink products that are assessed as high in fat, salt or sugar (HFSS) in

accordance with the nutrient profiling scheme published by the Food Standards Agency (FSA) on 6 December 2005. Information on the FSA’s nutrient profiling scheme is available on the FSA website.

Under-16 and under-18

Appendix 1: Advertising of other restricted products


Gambling rules Age at which rules apply

The Broadcasting Committee of Advertising Practice (BCAP) codes on gambling state:

17.4 Advertising for gambling must not:17.4.4 exploit the susceptibilities, aspirations, credulity, inexperience or lack of

knowledge of under-18s or other vulnerable persons17.4.5 be likely to be of particular appeal to under-18s, especially by reflecting or being

associated with youth culture

The BCAP codes on advertising of lotteries apply only to under-16s but follow similar restrictions.

Under-16 and Under-18

Alcohol rules Age at which rules apply

The Broadcasting Committee of Advertising Practice codes on alcohol state:

19.15 Television only – Alcohol advertisements must not: 19.15.1 be likely to appeal strongly to people under 18, especially by reflecting or being

associated with youth culture or showing adolescent or juvenile behaviour19.15.2 include a person or character whose example is likely to be followed by those

aged under 18 years or who has a strong appeal to those aged under 18.

19.16 Radio only – Alcohol advertisements must not:19.16.1 be targeted at those under 18 years or use a treatment likely to be of particular

appeal to them.19.16.2 include a person or character whose example is likely to be followed by those

aged under 18 years or who has a particular appeal to those aged under 18.

Guidance notes for broadcast alcohol advertising rules give further examples of advertising that should be avoided including ‘puppets or cute lovable animals’ and ‘cartoons, rhymes or animations’

Under-18

Food rules Age at which rules apply

Foods that are high in fat, sugar or salt are banned from being advertised on shows with a strong appeal to under-16s or shown on children’s television. The Broadcasting Committee of Advertising Practice codes defines these as:

32.5.1 food or drink products that are assessed as high in fat, salt or sugar (HFSS) in accordance with the nutrient profiling scheme published by the Food Standards Agency (FSA) on 6 December 2005.

Under-16

Registered Charity No. 221124 PCR7/09/14

By Jake Mcleod and Sam Royston

©The Children’s Society September 2014

To find out more about the issues raised in this report, please contact:

Jake [email protected]

Or Sam [email protected]

childrenssociety.org.uk/debt

playday not payday:

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